M7, Drafting Your Own PIO Reply, AI Evaluated

Module 7 of 10. This is the drafting module. Reading time about 25 minutes, drafting time about 60 to 90 minutes for five scenarios. AI evaluation runs at submission. End-of-module quiz plus drafting score unlock Module 8.

This module asks you to draft five PIO replies to five sample scenarios. After you submit each reply, a Large Language Model trained on RTI Wiki content will evaluate your draft against a rubric and assign a score. The AI score is added to your total course marks. The AI evaluation is NOT a human review and is NOT legal advice. It is a knowledge-of-RTI-Wiki score, indicative of how well you have absorbed the material.

Your reply is scored on five criteria, two marks each, for a total of ten per scenario, fifty across the module.

1. Statutory basis cited. Have you cited the right section of the RTI Act for every move? (For example, section 7(1) for disclosure, section 8(1)(X) for an exemption invoked, section 10 for severability, section 11 for third-party consultation, section 19(1) for the appellate paragraph.)
2. Section 8 / 9 / 24 invoked correctly. If you invoke an exemption, is it the right clause for the facts? Have you applied the test from the relevant case law (Girish Deshpande for section 8(1)(j), Aditya Bandopadhyay for fiduciary, RBI v Jayantilal Mistry for regulator records)?
3. Severability under section 10 applied. Where part of the record is exempt and part is disclosable, have you severed and supplied the non-exempt part with a redaction note? If a blanket refusal is your default, you lose points.
4. Appellate-right information included. Have you named the First Appellate Authority with designation, address, and contact? Have you mentioned the thirty-day appeal window?
5. Reasoned and time-bound. Is the reply reasoned, with specific findings? Is the dispatch date within thirty days of receipt? Have you applied the section 7(7) pause or the section 7(3) pause where applicable?

Before you start typing, run through the Module 6 analytical pass and the Module 4 template structure. Identify:

1. The items in the application.
2. The natural authority for each item.
3. The third-party triggers.
4. The exemption clauses (if any).
5. The severability opportunities.
6. The public interest under section 8(2).

Then sit down to draft. Use the Module 4 template. Replace bracketed fields with the facts of the scenario.

You are the PIO of a State Public Works Department. An applicant has filed an RTI requesting:

1. The technical bid documents of all bidders in Tender No. PWD/2024/045 for road repair in District X.
2. The financial bid documents and the comparative statement.
3. The file noting on the award.
4. The names of officers in the tender committee and their evaluation marks.
5. The names of unsuccessful bidders.

Application received on 02-01-2026. Tender was awarded on 10-12-2025. Successful bidder is ABC Constructions Pvt Ltd at a contract value of Rs 12.4 crore. Three unsuccessful bidders. All bidders had marked their financial bid sheets confidential under the Bid Submission Protocol.

Draft your reply.

What the AI will look for:

1. Section 11 notice issued within five days to all four bidders.
2. Section 8(1)(d) invoked for unsuccessful bidders' confidential financial bids, with the test applied (commercial confidence, harm to competitive position, larger public interest).
3. Section 10 severability, the successful bidder's bid, the contract value, the award note are disclosed. The unsuccessful bidders' confidential financial detail is redacted with a section 10 foot-note.
4. The names of tender committee officers are disclosable (CIC settled position on officers' names in their public functions).
5. Section 8(2) public interest finding recorded.
6. FAA contact paragraph included.
7. Dispatch within thirty days (subject to section 7(7) pause for section 11).

You are the PIO of a Central Government Ministry. An applicant has filed an RTI requesting:

1. The Annual Confidential Reports of Shri Y, Joint Secretary, for the last five years.
2. Details of any disciplinary proceedings against Shri Y.
3. Shri Y's leave record, asset declaration, and integrity certificate.
4. The file noting on Shri Y's recent promotion order.

Applicant has not stated any reason. Shri Y is currently posted and serving.

Draft your reply.

What the AI will look for:

1. Section 11 notice issued to Shri Y as third party.
2. Section 8(1)(j) invoked for ACR, asset declaration, and integrity certificate, with the Girish Deshpande test applied (information is personal, no clear public activity relationship, unwarranted invasion absent larger public interest).
3. Burden on applicant to show larger public interest. Since none stated, exemption upheld.
4. Disciplinary proceedings, if any, examined. If concluded and major-penalty order passed, disciplinary outcome may be disclosable as it relates to public functioning. If ongoing, section 8(1)(h) examination.
5. Leave record, generally exempt under section 8(1)(j) on Girish Deshpande line.
6. Promotion order, the order itself is a public document and disclosable. The file noting is examined for personal information, redactable under section 10.
7. Section 8(2) public interest, finding recorded.
8. FAA paragraph included.

You are the PIO of a District Hospital. An applicant, the son of an admitted patient, has filed an RTI at 11 am today requesting:

1. The medical case file of his mother, admitted three days ago in ICU.
2. The treatment protocol being followed.
3. The names of attending doctors.
4. The hospital's available specialists who can be called for a second opinion.

Patient is critical. The application explicitly states urgency.

Draft your reply.

What the AI will look for:

1. Treatment as a life-and-liberty matter under proviso to section 7(1). Forty-eight-hour disposal.
2. Disclosure of the medical case file to the next of kin under section 2(f) read with section 8(1)(j) third prong. The patient is the data subject and the son is a legitimate kin under common medical ethics. Most CIC orders support disclosure to next of kin in critical care.
3. Treatment protocol disclosed as held by the hospital.
4. Names of attending doctors disclosed.
5. Specialist list disclosed.
6. Reply dispatched within forty-eight hours, preferably by hand.
7. FAA paragraph included.

You are the PIO of a Central Government Ministry of Steel. An applicant has filed an RTI requesting:

1. The pension files of retired employees of a Public Sector Steel Company.
2. The medical benefit policy of the same Company.
3. The Company's annual report and audited financial statements.

The Public Sector Company is a separate public authority with its own PIO.

Draft your reply, including the section 6(3) transfer.

What the AI will look for:

1. Section 6(3) transfer to the Public Sector Company PIO within five days.
2. Transfer letter with inward reference, subject, applicant contact.
3. Copy of the transfer letter to the applicant.
4. The Ministry's own holding of any relevant policy directions on the Company examined and supplied to the extent held.
5. No demand for fee on items transferred (the transferee will assess fee).
6. Item-wise reply on what the Ministry holds and what it does not.
7. FAA paragraph included.

You are the PIO of a Central Government Department of Revenue. An applicant has filed an RTI requesting:

1. The intelligence reports of the Directorate of Revenue Intelligence (DRI) on alleged smuggling in a port.
2. Any administrative correspondence between the Department and DRI on the matter.
3. The action taken on allegations of corruption against named DRI officers in the port operations.

DRI is a Second Schedule organisation under section 24.

Draft your reply.

What the AI will look for:

1. DRI's intelligence reports, examined under section 24 exclusion. Intelligence content excluded. Section 6(3) transfer to DRI for the matters held by DRI.
2. Administrative correspondence is held by the Department. Disclosable subject to section 8 examination on a per-item basis. Routine administrative correspondence is not excluded under section 24.
3. Corruption allegations against DRI officers, covered by the corruption carve-out in the section 24 proviso. The information must be supplied (not excluded), subject to section 8(1)(j) and (h) examination on individual items.
4. Reasoned analysis recorded for each item.
5. FAA paragraph included.

For each scenario, write the reply in the textbox provided. The system will save your draft, run the AI rubric, return a score per criterion and an overall score with line-level feedback. The AI will quote your own text and explain why it scored as it did. You can revise once and resubmit, the second submission is final.

After all five scenarios are submitted, the system will compute your M7 total out of fifty. This score will be added to your total course marks under the drafting weight.

1. The AI is trained on RTI Wiki content, not on your jurisdictional High Court orders. If you cite a local High Court judgment that the AI does not know, the AI will not penalise you, but it will not credit you either.
2. The AI will reward the structure (item-wise, statute-cited, severed, reasoned, FAA-contacted) over rhetorical flourish. Plain professional prose scores higher than ornate language.
3. The AI will penalise blanket refusals, bare exemption citations, missing FAA contact, and absence of severability analysis.
4. The AI score is indicative. It is NOT a substitute for review by your senior PIO, law officer, or for actual legal advice in a real case.

This module is where you become a PIO who can draft. The score you get here is a measure of how well you have absorbed Modules 1 to 6. If you score below thirty out of fifty, do not proceed to Module 8. Re-read Modules 4, 5, and 6 and retake the drafting.

For working PIO templates and the live PIO Reply Checker tool, see PIO Reply Checker on RTI Wiki.

This module is part of the RTI Wiki PIO Certification Course. The course is a Learner Certificate programme. It is NOT accredited by any government or statutory body. The drafting exercises in this module are evaluated by a Large Language Model trained on RTI Wiki content, not by human evaluators. Scores are indicative knowledge measures, not legal advice.

Submit the M7 drafting scenarios, then take the M7 quiz to proceed to M8.